ML20198E309

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Forwards Response to Generic Ltr 85-12 Re Implementation of TMI Action Item II.K.3.5, Automatic Trip of Reactor Coolant Pumps
ML20198E309
Person / Time
Site: Beaver Valley
Issue date: 10/10/1985
From: Carey J
DUQUESNE LIGHT CO.
To: Thompson H
Office of Nuclear Reactor Regulation
References
TASK-2.K.3.05, TASK-TM GL-85-12, TAC-49695, NUDOCS 8511130283
Download: ML20198E309 (12)


Text

.

'Af Telephone (412) 393-6000 Nuclear Group P.O. Box 4 Shippingport PA15077-0004 October 10, 1985 ector of Nuclear Reactor Regulation United' States Nuclear Regulatory Commission Attn: Mr. Hugh L. Thompson, Jr. Director Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Oocket No. 50-334, License No. OPR-66 Implementation of TMI Action Item II.K.3.5, "Autmatic Trip of Reactor Coolant Pumps" (Generic Letter No. 85-12)

Gentlemen:

In response to your letter of June 28, 1985, Generic Letter 85-12, the following information is submitted regarding the Reactor Coolant Pump (RCP) trip issue. In particular, we nave selectec appropriate RCP trip criteria based upon the Westingnouse Owner's Group (WOG) methodology whicn nas been included in the WOG Emergency Response Guidelines (ERGS). In our response of April 18, 1983, to Generic Letter 83-10d, we indicated our plans to include tne WOG methodology in our new symptom-based Emergency Operating Procedures for Beaver Valley Power Station, Unit No. 1 (BVPS-1) and have since utilized the WOG ERGS, Revision 1 for this purpose. The schedule for the implementation of the new E0Ps has since been confirmed by Commission Order dated the 12th of June 1984. ,

In reviewing the WOG RCP trip criteria, the Commission notes that the process of criterion selection involves a number of plant specific considerations. Accordingly, your letter indicated the need to provide the information requested in Section IV of the Safety Evaluation for the WOG (Enclosure to Generic Letter 85-12). The information contained in the Attachment to this submittal details our responses to eacn requested item of Section IV in order to complete our response to Generic Letter 83-10d and subsequently Generic Letter 85-12.

If you have any questions regarding this submittal, please contact myself or memoers of my staff.

Very truly yours,

$ O

$34 Pag ice Pr ident, Nuclear O

n-80 aver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Implementation of TMI Action Item II.K.3.5, " Automatic

-Trip of Reactor Coolant Pumps" (Generic Letter No. 85-12)

Page 2-cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington,-DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One' James River Plaza Richmond, VA 23261 l

1 l

l ATTACHMENT Response to Generic Letter 85-12 Implementation of TMI Action Item II.K.3.5

" Automatic Trip of Reactor Coolant Pumps" l

A DETERMINATION OF RCP TRIP CRITERIA A.1 Identify the instrumentation to be used to determine the RCP trip setpoint, including the degree of redundancy of each parameter signal needed for the criterion chosen.

Response

The following is based upon the WOG methodology as provided in the ERGS, Revision 1, for the calculation of alternative RCP trip criteria, and consideration of . instrumentation qualification and uncertainties. We nave calculated the BVPS-1 RCP trip setpoints for each of the alternative parameters and have selected the Secondary Pressure Dependent.RCS Pressure criterion. With this method, the RCS Pressure Setpoint is determined based on the actual steam generator pressure. We have determined tnat the selected parameters satisfy the discrimination tequirements in NRC Generic Letter 83-10d. Provided below is the requested information for the instrumentation to be used for the criterion chosen.

RCS Wide-Range Pressure (0-3000 PSIG) P-RC-402 and P-RC-403

a. Senscrs (PT-RC-402, 403)

Rosemount Model 1154GP9RB Gage Transmitter

b. Racks (P-RC-402, 403) g 7100 Series Rack Modules
c. Indicators (PI-RC-402A, 403):

y Model 43-VX-252 Steam Generator Pressure (0-1400 PSIG) P-MS-474,475,476 /484,485,486 /494,495,496

a. Sensors (PT-MS-474,475,476 /484,485,486 /494,495,496)

ITT Barton Model 763 Gage Transmitter

b. Racks (P-MS-474,475,476 /484,485,486 /494,495,496)

W 7100 Series Rack Modules

c. Indicators (PI-MS-474, 474A, 475, 476, 484, 485, 485A, 486, 494, 495, 496, 496A)

W Model 43-VX-252 The wide-range RCS pressure indicators are safety grade quality and redundancy exists (2 channels-loop A and C). For the secondary pressure indicators, redundancy exits for each loop (3 channels per loop). The above instruments are environmentally qualified for the design basis accident under which they are required for mitigation.

Att chment

. Page 2 A.2(a) Identify the instrumentation uncertainties for both normal and adverse containment conditions.

Response

Normal Indication Accuracy (NIA)*

Loops: P-RC-402/403 NIA = 1 71. PSIG Loops: P-MS-474,5,6 / 484,5,6 / 494,5,6 NIA = 1 40 PSIG Post Accident Indicator Accuracy (PIA)

  • Loops: P-RC-402/403 PIA = 1 371 PSIG Loops: P-MS-474,5,6 / 484,5,6 / 494,5,6 PIA = 1 250 PSIG
  • Instrument uncertainty values are rounded upward to the nearest full PSI for additional conservatism.

A.2(b) Describe the basis for selection of the adverse containment carameters:

Response

'The ERGS, Revision 1, have been used to develop the BVPS-1 new E0Ps.

The parameter setpoints (i.e. RCP Trip Parameters, etc.) in the E0Ps have been established by using the WOG methodology and by considering the associated instrument uncertainties. One factor which affects the instrument uncertainties is the environmental conditions which vary for

'the type and severity of an accident. Two sets of parameter values for the RCP trip criterion are provided in the E0Ps, one for normal conditions and one for post accident conditions, i.e. adverse containment conditions. The operator uses one or the other set of values, depending on containment pressure and radiation conditions. The selection .of the pressure and radiation values which determine adverse

-containment conditions is based on the ERG defined values (

Reference:

ERG, Executive Volume, Generic Instrumentation Section). If either the containment pressure exceeds 5 psig or the containment radiation exceeds 10E5 R/hr., the ERG values, tne E0P adverse containment (post accident) parameter setpoint is implemented by the operator. If the containment conditions are less than these values, the E0P normal parameter setpoint is-used.

A.2(c) Address, as appropriate, local conditions such as fluid jets or pipe whip whicn might influence the instrumentation reliability.

Response

A review of plant drawings and instrument locations, including sensing lines and electronics, has been completed and it has been determined

. Attr.chment-

. Page 3 that no single failure as described in our UFSAR will result in a fluid jet or pipe whip resulting in the common cause loss of all instrumentations used to monitor the RCP trip setpoint. Sufficient redundancy and separation exists to preclude this from occurring.

A.3 In addressing the selection of the criterion, consideration to uncertainties associated with the WOG supplied analyses values must be provided. These uncertainties include both uncertainties in the computer program results and uncertainties resulting from plant specific features not representative of the generic data group.

Response

The LOFTRAN computer code was used to perform the alternate RCP trip criteria analyses. Both Steam Generator Tube Rupture (SGTR) and non-LOCA event were simulated in these analyses. Results from the SGTR analyses were used to obtain all but three of the trip parameters.

LOFTRAN is a Westinghouse licensed code used for FSAR, SGTR and non-LOCA analyses. The code has been validated against the January 1982 SGTR event at the Ginna plant. The results of this validation show that LOFTRAN can accurately predict RCS pressure, RCS temperatures and

. secondary pressures especially in the first ten minutes of the transient. This is the critical time period when minimum pressure and subcooling is determined.

The major causes of uncertainties and conservatism in tne computer program results, assuming no changes in the initial plant conditions (i.e. full power, presurizer level, all SI and AFW pumps running) are due to either models or inputs to LOFTRAN. The following are considered to have the most impact on the determination of the RCP trip criteria:

1. Break flow
2. SI flow
3. Decay heat
4. Auxiliary feedwater flow The following sections provide an evaluation of the uncertainties associated with each of these items.

To conservatively simulate a double ended tube rupture in safety analyses, the break flow model used in LOFTRAN includes a substantial amount of conservatism (i.e., predicts higher break flow than actually expected). Westinghouse has performed analyses and developed a more realistic break flow model that has been validated against the Ginna SGTR data. The break flow model used in tne WOG analyses has been shown to be 'approximately 30% conservative when the effect of the higher predicted break flow is compared to the more realistic model. The consequence of the higher predicted break flow is a lower than expected predicted minimum pressure.

The SI flow inputs used were derived from best estimate calculations, assuming all SI trains operating. An evaluation of the calculational methodology shows that these inputs have a maximum uncertainty of + 10%.

n_ ,

Attachment

..T

'Pige14-

!The decay heat'mo' del used in the WOG analyses was based on the 1971 ANS 5.1 standard. When compared -with the-more_recent 1979 ANS 5.1 decay 1 heat : inputs, -the . values used in the WOG analyses are higher by about-

- 5%., To idetermine the effect of the' uncertainty due to the decay heat model, a sensitivity study wasiconducted for SGTR.. The results of this

, study' show :that a: .20% ' decrease in decay heat resulted in only a 1%

decrease Ein ;RCS pressure for the first 10 minutes of the transient.

Since JRCS temperature.is controlled by steam relief, it is not affected by the decay heat model uncertainty- .

.The AFW flow. rate input used .in the WOG analyses are best estimate values, : assuming that all auxiliary feed pumps are running, minimum pump start delay, and no throttling. ETo evaluate the uncertainties with AFW flow,' rate, a sensitivity study was performed. Results from the two loop plant _ study show that,:a 64% increase in AFW flow'resulted in only an 8%

. decrease in minimum. RCS pressure, a 3% decrease in minimum RCS

- subcooling, and an 8% decrease in minimum pressure _ differential.

-Results from the 3 loop plant study show that, a 27% increase in AFW

-flow resulted in only ,a 3% decrease in minimum RCS pressure, a 2%

idecrease_'in minimum RCS subcool'ng, and a 2% decrease in pressure differential,

~The effects of all~ these- uncertainties with the models and input parameters were evaluated and it was concluded that the contributions from the break flow conservatism and the SI uncertainty dominate. The calculated overall uncertainty in the WOG analyses as a result of these considerations for the Beaver Valley Power Station Unit 1-is -30 to L+300 PSI for the RCS/ Secondary Differential Pressure RCP trip setpoint.

Due to the minimal effects from the decay heat model and AFW input, these results' include only the effects of the uncertainties due to the creak-flow model and SI flow inputs.

-8 POTENTIAL REACTOR COOLANT PUMP PROBLEMS

.B.1 Assure that containment isolation, including inaavertent isolation will not cause problems if it occurs for non-LOCA transients and accidents.

a. Demonstrate that, if water services needed for RCP operations are terminated, they can be restared fast enough once a non-LOCA situation is confirmed to prevent seal damage or

. . failure.

b. Confirm that containment isolation with continued pump

-operation will not lead to seal or pump damage or failure.

Response-The. water services needed for RCP operation includes a) the reactor plant component cooling water system (CCR) which supplies cooling water for the 'RCP thermal barrier neat exchangers and for the RCP motor bearings oil neat exchangers and b) the RCP seal injection flow which is provided by the charging /HHSI pumps.

. Attachment

.. P g] 5 l l

l The- design and operation of the RCP seal injection flow is such that it

. remains in service under anticipated plant transients. Neither containment isolation phase A or B (CIA or CIB) will isolate RCP seal injection flow. The seal injection flow by itself is adequate for providing RCP seal cooling which prevents seal damage or failure.

Therefore, RCP seal damage or failure is precluded due to the continued

. supply of seal injection water.

l The CCR flow is maintained during a CIA signal which therefore permits continued RCP operation. In the event a CIB occurs, CCR flow to the RCP's is terminated which will result in stopping the RCPs within L

approximately five minutes. CCR flow is necessary for RCP operation since it is the source of cooling for the RCP motor bearings oil heat exchangers, however, limited operation is possible without pump damage or failure occurring. CCR flow cannot be restored fast enough following a CIB signal to maintain the RCP's running. The new symptom-based Emergency Operating Procedures (EOPs) provide restart instructions in the event RCP operation is desired. This is consistent with the ERG

-background documents and the general philosophy that RCPs should be operating to aid in plant cool down and RCS pre;,sure control for non-LOCA transients and accidents.

Additional information on containment isolation is provided in UFSAR Section 5.3.3. Table 5.3-1 identifies the various containment isolation arrangements and states what isolation signals exist for these water systems supporting RCP operation.

The following provides assurance that upon receipt of a CIB signal, the

-operator will take the appropriate action.

1. Through training, the operators are instructed that if CCR water flow to the RCPs is isolated on a containment pressure signal, all the RCPs should be stopped within 5 minutes because of loss of RCP motor bearing oil cooling. The current E0Ps contain cautions to this effect where appropriate.
2. In the new symptom-based E0Ps, one of the operator immediate action steps in E-0, " Reactor Trip or Safety Injection", instructs the operator to stop all RCPs upon verification that CIB is required. A subsequent E-0 step instructs the operator to stop all RCPs if there is no CCR flow to the RCPs.
3. The operator would be alerted to the RCP conditions and the need to trip the RCPs since one or several monitors would alarm in the control room. These alarms are symptomatic of the loss of CCR water flow and include the following:

RCP Alarms Related to CCR Flow Loss:

1. RCP Lower Bearing Lube Oil Cooling Water Flow Low
2. RCP Stator Winding Cooling Water Flow Low I

Ja l-

, ! Attachment'

. 'Page 6

3. RCP Upper Bearing Lube Oil Cooling Water Flow Low
4. RCP Motor Bearing Temperature High
5. RCP Lower. Radial Bearing Temperature High
6. RCP Cooling Water Discharge Temperature High
7. RCP Thermal Barrier Cooling Water Discharge Temperature High Alarms Related to the CCR System
1. CCR Water Surge Tank Level Hign-Low
2. CCR Water Heat Exchanger 8" Discharge Line Flow Low-
3. CCR Water Heat Excnanger 14" Discharge Line Flow Low
4. CCR Pump Discharge Pressure Low
5. CCR Pump Auto Start-Stop.
6. High Temperature Alarms on Numerous Components.

r-It is notea that, if RCP operation (at least one pump) becomes desirable, -the new E0Ps provide for RCP restart unaer the appropriate conditions (see response to C2 herein for RCP Restart steps). Also, there are two function restoration procedures, FR-C.1 and FR-P.1, where special RCP restart (i.e., without RCP support conditions required) is considered necessary. The conditions for RCP restart are discussed in the ERGS, Executive Volume, RCP Trip / Restart, Section 2.4 and provided in the symptom-based E0Ps.

B.2 Identify. the components required to trip the RCPs, including relays, power supplies and breakers. Assure that RCP trip, when determined necessary, will occur.- If necessary, include the effects of adverse containment conditions on RCP trip reliability. Describe the basis for the adverse _ containment parameters selected.

Response

Based on manual RCP trip, the following set of components and locations are identified for each RCP. The mark numbers or other identification

.information are delineated below for RCP-1A, 18 and 10, respectively.

Component Description Identification

1. Air Circuit Breakers'(ACB) 1AS, 185, and ICS
2. Local Control Power Breakers 125VOC Heineman
3. Cell Swite.hes 52H-1A5, 52H-185, & 52H-1C5 1

o Attachment

,_ P:ge 7 4 Auxiliary Contacts 52-1A5,52-185, & 521C5

5. Disconnecting Contacts. One each for eacn ACB
6. Trip Coils One each for each ACB
7. Control Power Supp'y (125VDC) Bus 1-1A Breaker 1, Bus 1-1A Breakers Breaker 2, and Bus 1-2A Breaker 1.
8. Control-Switches 1-1AS, 1-185, and 1-1C5 Components 1 through 6 are locatea in the normal switchgear room, components 7 in the process instrument room, and components 8 are located on the bench board in the control room. It is not necessary to 1

-include the affects of adverse containment conditions on RCP trip reliability since the above equipment is not subject to high energy line breaks and the environment of the rooms in which they are located is not anticipated to be significantly different than the environment that would occur during normal-plant operation.

Assurance that RCP trip, when determined necessary, will occur is providea by the following:

1. Preventive maintenance having a 18 month frequency is performed on the RCP breakers. - '
2. The RCPs are controlled from the oenchboards in the control room.

Switch positions are STOP -

START with red (running) and white (normal-shutdown or bright-auto trip) status indicating lights.

Also available in the control room, are motor ammeter indication for each RCP and flow indication for each reactor coolant loop.

In the event that this instrumentation snows that an RCP has not tripped when manually tripped from the main control board by the operator, the operator can then manually trip the RCP at the pump breaker in the switchgear room.

C OPERATOR TRAINING AND PROCEDURES (RCP Trip)

C.1 Describe the operator training program for RCP trip. Include the general philosophy regarding the need to trip pumps versus the desire to keep pumps running.

Response

The selection and implementation of the RCP trip criterion is based on the WOG methodology. The methocology nas been chosen within the WOG generated Emergency Operating Procedures (EOPs) and is being presented to all licensed operators and STAS during the Training Program for these new E0Ps. A description of this pnase of training and philosophy is stated below.

RCP operation is of a concern during small break LOCA events. Accident analysis determinations are based on the assumption that offsite power is lost at the onset of the l

3 JAtt:chmentL

. :Page.8 event. This is . not necessarily a conservative assumption during a. small break .LOCA. .The peak cladding temperature s t limit of ,2200*F may be exceeded if, the RCP's trip after reaching; a- critical time -period. The RCP trip criteria is based -on tripping the RCP's prior to reaching this critical time.

If RCP's are not running during the event, RCS inventory will decrease to a level below .the break elevation. When.this occurs only. steam is released out of the break. With RCP's running, a steam water mixture is forced out of the break.

This .results .in a' larger amount of' mass loss.from the RCS.

The forced . circulation, however, also results in an increase in core- cooling. The critical time period is when the

-increased inventory' loss results .in a deeper core uncovery when the pumps trip and.the core has not been cooled'enough to prevent exceeding the peak cladding temperature limit.

The RCP trip criteria and. training ensures that the operator will trip the pumps prior to reaching the critical time period. The increase in RCS mass loss due to RCP's running does not occur until the break would have uncovered had pumps

'not been running. The break cannot uncover until the primary si_de of- the _S.G. U-tubes have drained and this cannot begin until -saturation . conditions are reached at the top of the-U-tubes, thereby allowing steam to fill the void created by draining. The saturation conditions at the top of the U-tubes depends on- RCS pressure and temperature and the conditions in the secondary system. The RCS temperature is

' dependent on. the-secondary temperature and its corresponding secondary pressure. The secondary pressure may vary due to the means of = steam relief being used. For example, the secondary pressure vill be less if steam is dumped to the main . condenser rat ar than relieved through -the code safeties. For the actual secondary pressure and the associated  : primary to secondary . temperature differential needed for~ heat transfer through the U-tubes, there is a corresponding RCS pressure which indicates that the RCS is approaching saturation at the top of the U-tubes. The resultant crimary to secondary pressure differential provides the criterla for tripping the RCPs.

The criterion for tripping the RCP's is RCS pressure 145 psi greater than the highest SG pressure for normal containment conditions and 510 psi for adverse containment conditions.

This number is derived from summing primary to secondary, delta-P. corresponding to the delta-T required for heat transfer, height difference of the U-tubes to the pressure instruments, steamline delta-P, and instrument inaccuracies.

If primary to secondary delta-P decreases to the trip setpoint of 145 psi and high head SI flow is verified, the RCP's must be tripped.

. .m ., , _ - _. .. - _ _ . _ . - _ _ _ . . . . . . _ _. . __. .- .

  1. Attachment-P:ge 9 L4

, - - j0uring. non-LOCA . events, ,it is desired to keep RCP's running -

to provide. normal RCS pressure. control, (i.e., spray flow) p and . vessel- head cooling. If pumps are tripped during a:SGTR

! j.c .or 'other non-LOCA events, pressurizer PORV's would have to be utilized to reduce RCS pressure. -The preferrea method is to .

utilize pressurizer sprays which are most effective when the RCPs -are operating. The 145 psi primary to secondary delta-P trip criteria ~.provides protection ~ during .small break LOCA

events, while ensuring pumps are not. tripped during a design
basis: SGTR- event of a~ single tube,,and selected non-LOCA
events. The non-LOCA events analyzed are a steam break and a

-.feedline -break. The analysis shows that primary:to secondary-delta-P should not decrease below 350 psi for these events.

. RCP.'s will not be tripped during a SGTR or non-LOCA event H ~ unless_ containment . pressure rises- to 10 psig and CIB  ;

actuates. The resulting loss of CCR to-the RCP's would then require that they be tripped.

C.2. Identify those procedures which inclu'de RCP trip related operations.

a. RCP trip using WOG alternate criteria

'b. RCP restart ,

l

c. Decay. heat removal by natural circulation
d. Primary sytem void removal e .- Use of steam generators with and without RCPs operating, f-. RCP trip for other reasons.

Response

The BVPS-1 .EOPs have been developed based on the WOG ERGS, Revision 1,

~

l

.and the E0P -designations are the same as in the ERGS. 'We believe that-

'this response and the review of this response -can therefore -be

,_ .faciliated by reference to Table 4, Section 2.6, of the ERG Generic i Issue, .RCP Trip / Restart and by identifying any differences for the

.BVPS-1 ~E0Ps. The ERG Table 4 provides a summary of RCP Trip and Restart- "

steps as contained in the BVPS-1 E0Ps except as noted below..

g ECA-3.2 . Add a special trip step (ST) relative to inadequate RCS subcooling and RVLIS not operable.

FR-C.1 Add a special restart without support conditions required.

(SR)

FR-P.1 Replace the Table 4 restart criteria (R) with SR (Refer-ence Section 2.4.4, ERG Generic Issue RCP Trip / Restart).  ;

E-0, E-1, Add an "or" condition in conjunction with each trip (T).

E-3 and-

~

ECA-2.1 L ECA-1,1 .. Add an "or" condition in conjunction with trip (TI). The l , conditions for these last two groups of trips relate to loss [

of reactor plant component cooling water (CCR) flow.

l

- , , ,, _.-....,---,.__..-.___,_.m.._-~,--,- ,- . , - . - - - . , , _ . .

~

f'" w

-, :Attacnment-Pag 3 10 LE Add ST for RCPs supplying failed spray valve.

Future -changes to these E0Ps would be performed in accordance with our program as. described in our Procedures Generation Package submitted for NRC review on June 28,- 1984.

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